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Overview

This guide will walk through the complete process of business verification within the Dwolla API, including creating a business verified Customer, handling verification statuses, adding beneficial owners, and certifying beneficial ownership. A business verified Customer represents a business that intends to send or receive funds on your platform. In any transaction, at least one party—either the sender or the receiver—must complete the identity verification process as outlined in this guide. The business verification process consists of the following key steps:
1

Creating a Business Verified Customer

Learn how to create a business verified Customer in Dwolla, including required information for different business types and how to submit the initial verification request.
2

Handling Business Verified Customer Statuses

Understand the possible verification statuses, how to handle retry and document requests, and what to do if additional information is needed for verification.
3

Adding Beneficial Owner(s)

Add and verify beneficial owners for your business Customer, including required information and how to check their verification status.
4

Certify Beneficial Ownership

Certify that all beneficial owner information is correct to fulfill compliance requirements and enable your business Customer to send funds.

Key Terminology

  • Account Admin - The representative creating the business verified Customer on behalf of the business and Controller.
  • Controller - Any natural individual who holds significant responsibilities to control, manage, or direct a company or other corporate entity (i.e. CEO, CFO, General Partner, President, etc). A company may have more than one controller, but only one controller’s information must be collected.
  • Beneficial owner - Any natural person who, directly or indirectly, owns 25% or more of the equity interests of the company.
  • Beneficial ownership certification - An action taken by the Account Admin to confirm that the information provided is correct.
  • EIN (Employer Identification Number) - A unique identification number that is assigned to a business entity so that they can easily be identified by the Internal Revenue Service.

Step 1 - Creating a Business Verified Customer

Creating a business verified Customer will require you to provide information about the business entity as well as a Controller, if required.

Business Verified Customer Quick Guide

There are two types of business verified Customers that you can create, based on if they are required to add information on the Controller or not.

Create a business verified Customer with no Controller

Follow these steps to create a business verified Customer where "businessType": "soleProprietorship"
Events
As a developer, you can expect these events to be triggered when a business verified Customer is successfully created and systematically verified:
  1. customer_created
  2. customer_verified

What parties are identity verified by Dwolla?

In order to create a business verified Customer with businessType of soleProprietorship, Dwolla only requires information to verify the identity of the business and the Account Admin.

Sole Propreietorship - Request parameters

Sole Propreietorship - Request and response

Create a business verified Customer with controller

Events

As a developer, you can expect these events to be triggered when a business verified Customer is successfully created and systematically verified:
  1. customer_created
  2. customer_verified

What parties are identity verified by Dwolla?

For all other businessType’s other than soleProprietorship, your Customer will need to provide more information for verification. In order to create a business verified Customer with a controller, Dwolla requires information on an account admin, the business, and the controller. Your business verified Customer account admin will act as the agent signing up on behalf of the business. When going through the Customer creation flow, your business verified Customer account admin will only need information on one controller to successfully complete the signup flow.

Corporation, partnership, llc - Request parameters

Controller JSON object
Controller address JSON object
Controller passport JSON object
Once you submit this request, Dwolla will perform some initial validation to check for formatting issues such as an invalid date of birth, invalid email format, etc. If successful, the response will be a HTTP 201/Created with the URL of the new Customer resource contained in the Location header.

Business with Controller - Request and response

Check the status of the business Customer

You have created a business verified Customer; however, the successful creation of a business verified Customer doesn’t necessarily mean the Customer account is verified. Businesses may need to provide additional information to help verify their identity. It is important to check the status of the business Customer to determine if additional documentation is needed.

Request and response

You will want to ensure that both your Controller and your Business have been verified, as the Customer will be unable to send or receive funds until then. If the Customer is in retry or document status, head to the next step to learn how to handle these statuses.

Step 2 - Handling Business Verified Customer Statuses

You have successfully created a business verified Customer; however, there are cases where Dwolla will need more information to fully verify the identity of the Controller and/or Business. Read on to learn more.
If your Business and Controller are already identity verified, you can skip to the next step adding beneficial owners to continue with your business verified Customer onboarding.

Verification statuses and corresponding events

As a developer, you will want to handle the various Customer statuses that can be returned.

Understanding Verification Directives

When further action is required for a Business Verified Customer to become verified, the Dwolla API includes Verification Directives in the _embedded.errors array of the Retrieve a Customer response. These directives explain the outstanding requirements for verification, provide actionable instructions, and include hypermedia links (_links) to enable resolution. By parsing and utilizing these directives, you can build a dynamic and user-friendly interface that guides your end-users through the necessary steps, minimizing onboarding friction and reducing support overhead.
See how to simulate these verification directives in the Sandbox testing guide.

Structure of a Verification Directive

Each object within the _embedded.errors array represents a single Verification Directive and follows this structure:
  • code: A specific, machine-readable string identifying the type of verification issue. Use this code in your application logic to handle different error scenarios.
  • message: A human-readable string explaining the issue and providing guidance on how to resolve it. This message is intended to help you inform your end-users about the required actions.
  • _links: A HATEOAS object containing relevant links. This typically includes a link to the API resource needed to address the directive, such as updating the Customer resource or uploading a specific document type. The key of the link (e.g., “update-customer”, “upload-ein-document”) often indicates the required action. An empty _links object may be returned if no direct API action corresponds to the directive (e.g., for AdditionalReviewRequired).

Verification Directives

The following table lists common verification directives you may encounter for Business Verified Customers, along with their meaning and typical required actions:
Example Retrieve Customer response
Here’s an example of how the _embedded.errors array might look in a GET /customers/{id} response when multiple issues require attention:

Handling Multiple Directives

As demonstrated in the example response above, the _embedded.errors array can contain multiple Verification Directive objects simultaneously if several issues require attention. Your application should iterate through the entire errors array, presenting the guidance from each message to the end-user and providing access to all corresponding actions via the _links. Addressing all listed directives is necessary for the user to successfully complete the verification process.

Handling retry status

A retry status occurs when a Customer’s identity scores are too low during a verification attempt. Typically, a retry status occurs after the initial creation of a business-verified customer, however, a customer can also be placed into a retry status via the Dwolla Dashboard if the customer is in a document status. When the customer is in the retry status, your application needs to re-initiate the verification process by prompting the user via a form to resubmit their identifying information.
You need to gather new information if the Customer is placed into the retry status; simply passing the same information will result in the same insufficient scores.

Determining information needed to retry verification

When a business verified Customer is placed in the retry verification status, Dwolla will return a link in the API response after retrieving a Customer. The retry link contained within the _links object of the response helps your application determine if a retry is needed and what type of retry is required. What data you need to request from the customer depends on the retry scenario:
  • Business-only retry: A retry-verification link is returned. Include all fields required during initial customer but omit Controller information. For business verified Customers with Controllers, different links can be returned depending on whether retry is needed for just the business, or both the Controller and business.
  • Controller and business retry: A retry-with-full-ssn link is returned. If the Controller information needs to be retried, all fields that were required in the initial Customer creation attempt will be required in the retry attempt, along with the full 9-digit SSN of the Controller in order to give our identity vendor more information in an attempt to receive a sufficient score to approve the Customer account (see example request below).
Understanding _embedded errors
Additionally, _embedded errors are included in the Customer resource which include information about the next steps required to get the Customer verified (see example response below). Refer to the table below for the list of possible links and their descriptions.
Example response

Sole Proprietorship (retry-verification) - Request and response

Business with Controller (retry-verification) - Request and response

Business with Controller (retry-with-full-ssn) - Request and response

Handling document status

If the Customer has a status of document, the Customer will need to upload additional pieces of information in order to verify the account. Use the create a document endpoint when uploading a colored camera captured image of the identifying document. The document(s) will then be reviewed by Dwolla; this review may take up to 1-2 business days to approve or reject. You can provide the following best practices to the Customer in order to reduce the chances of a document being rejected:
  • Only images of the front of an ID
  • All 4 edges of the document should be visible
  • A dark/high contrast background should be used
  • At least 90% of the image should be the document
  • Should be at least 300dpi
  • Capture image from directly above the document
  • Make sure that the image is properly aligned, not rotated, tilted or skewed
  • No flash to reduce glare
  • No black and white documents
  • No expired IDs

Determining verification documents needed

When a business verified Customer is placed in the document verification status, Dwolla will return a link in the API response after retrieving a Customer, which will be used by an application to determine if documentation is needed. For business verified Customers, different links can be returned depending on whether or not documents are needed for a Controller, the business, both the Controller and business, or for the DBA (Doing Business As). Additionally, embedded errors are included in the Customer resource which include information about the next steps required to get the Customer verified (see example response below). Refer to the table below for the list of possible links and their description. Refer to the acceptable document types section for more information on what types of documents are accepted for businesses and Controllers.
Example response

Document Types

Controllers
US persons: A colored camera captured image of the Controller’s identifying document can be specified as documentType: license (state issued driver’s license), or idCard (U.S. government-issued photo id card). Supported Document Examples:
  • Non-expired State Issued Driver’s License/Identification Card
  • Non-expired US Passport
  • Federal Employment Authorization Card
  • US Visa
Unsupported Document Examples:
  • Military IDs
  • Expired government-issued IDs
Non-US persons: A colored camera captured image of the Controller’s identifying document can be specified as documentType: passport. Examples include:
  • Non-expired Foreign Passport Note: Foreign Passports are only accepted when the individual does not have an ITIN or SSN and the user must alternatively enter the Passport number.
Businesses
Documents that are used to help identify a business are specified as documentType other. Note: A DBA document should be issued by the government and should include the DBA name along with the state registered business name. Business Identifying documents we recommend uploading can include the following:
  • Partnership, General Partnership: EIN Letter (IRS-issued SS4 confirmation letter).
  • Limited Liability Corporation (LLC), Corporation: EIN Letter (IRS-issued SS4 confirmation letter).
  • Sole Proprietorship: Sole Proprietorships can be verified by uploading Business documents as well as Personal IDs. Personal IDs need to be specified as documentType idCard, license or passport depending on the type of the ID. Business documents need to be specified as documentType other. Acceptable documents include one or more of the following, as applicable to your sole proprietorship:
    • Business documents (documentType other):
      • Fictitious Business Name Statement,
      • Certificate of Assumed Name; Business License,
      • Sales/Use Tax License,
      • Registration of Trade Name,
      • EIN documentation (IRS-issued SS4 confirmation letter)
    • Personal documents (documentType license, passport or idCard):
      • Color copy of a valid government-issued photo ID (e.g., a driver’s license, passport, or state ID card).
Trusts should be created as Sole Proprietor accounts and will require signed trust documents that include the trust and username that are on file.
Other business documents may be acceptable on a case by case basis with Dwolla approval. These include any US government entity (federal, state, local) issued business formation or licensing exhibiting the name of the business enrolling with Dwolla, or; Any business formation documents exhibiting the name of the business entity in addition to being filed and stamped by a US government entity. Examples include:
  • Filed and stamped Articles of Organization or Incorporation
  • Sales/Use Tax License
  • Business License
  • Certificate of Good Standing
Proof of address
If Dwolla’s Compliance team is unable to find an external connection to confirm the user does in fact conduct business at their provided business address, a “proof of address” will be required. Proof of address are any of the following, current documents that show the address in question:
  • Utility Bill
  • Financial Statement
  • Tax Statement (Please note - Form W-9 is a tax form, and is not an acceptable Tax Statement)
  • Fully Executed Lease Agreement - must be valid for a minimum of the next 30 days.

Uploading a document

To upload a color photo of the document, you’ll initiate a multipart form-data POST request from your backend server to https://api.dwolla.com/customers/{id}/documents. The file must be either a .jpg, .jpeg, or .png. Files must be no larger than 10MB in size. Additionally, Business Documents can also be uploaded in a .pdf format. You’ll also get a with a customer_verification_document_uploaded event to let you know the document was successfully uploaded.

Request and response

If the document was successfully uploaded, the response will be a HTTP 201 Created with the URL of the new document resource contained in the Location header.

Document review process

Once created, the document will be reviewed by Dwolla. When our team has made a decision to approve or reject, which may take up to 1-2 business days, we’ll create either a customer_verification_document_approved or customer_verification_document_failed event. If the document was sufficient, the Customer may be verified in this process. If not, we may need additional documentation. Note: Reference the determining verification documents needed section for more information on determining if additional documents are needed after an approved or failed event is triggered. If the document was found to be fraudulent or doesn’t match the identity of the Customer, the Customer will be suspended.

Document failure

A document can fail if, for example, the Customer uploaded the wrong type of document or the .jpg or .png file supplied was not readable (i.e. blurry, not well lit, not in color, or cuts off a portion of the identifying image). If you receive a customer_verification_document_failed webhook, you’ll need to upload another document. To retrieve the failure reason for the document upload, you’ll retrieve the document by its ID. Contained in the response will be a failureReason field which corresponds to one or more of the following values. In case of a failure due to multiple reasons, an additional allFailureReasons of reasons and descriptions is also returned:
Request and response

Handling status: suspended

If the Customer is suspended, there’s no further action you can take to correct this using the API. You’ll need to contact support@dwolla.com or your account manager for assistance. The successful creation of a business verified Customer and Controller doesn’t necessarily mean the Customer is fully verified and eligible to transfer. After successfully creating your business verified Customer, you will need to check to see if the beneficial ownership requirements apply to you. To learn how to add beneficial owner(s) to your Customer, read on in the next step.

Step 3 - Adding Beneficial Owner(s)

To help the government fight financial crime, the existing United States Federal customer due diligence rules were amended to clarify and strengthen customer due diligence requirements. The customer due diligence rule imposes a requirement for verifying the identity of beneficial owner(s) of Dwolla’s partners and users that are not natural persons. These legal entities can be abused to disguise involvement in terrorist financing, money laundering, tax evasion, corruption, fraud, and other financial crimes. Requiring the disclosure of key individuals who ultimately own or control a legal entity (i.e., the beneficial owners) helps law enforcement investigate and prosecute these crimes.
If your business is exempt or if there is no individual with at least 25% ownership, your Customer can go straight to certifying that there are no beneficial owners

How do I know what business structure is required to add Beneficial Owners?

Create a beneficial owner for a Business Verified Customer

To create a beneficial owner, use the create a beneficial owner endpoint.
Events
As a developer, you can expect these events to be triggered when a beneficial owner is successfully created and systematically verified:
  1. customer_beneficial_owner_created
  2. customer_beneficial_owner_verified
Request Parameters
Address JSON object
Passport JSON object
Request and Response

Check the status of an individual Beneficial Owner

After a beneficial owner has been created, the beneficial owner’s identity needs to go through a verification process. A beneficial owner that has a status of incomplete or document will impact the business verified Customer’s eligibility to send or receive funds. When a beneficial owner has been successfully verified by Dwolla, the beneficial owner’s status will be set to verified. Reference the table below for more information on the events that correspond to each of the beneficial owner statuses:
Individual Beneficial Owner statuses and events
Let’s check to see if the Owner was successfully verified or not. We are going to use the location of the Beneficial Owner resource that was just created.
Request and response - retrieve a beneficial owner status

Handling an individual beneficial owner Status

Congrats! You have created a beneficial owner for a business verified Customer, however, the successful creation of a beneficial Owner doesn’t necessarily mean they are identity verified. You will want to ensure that the beneficial Owner is verified, as the business verified Customer will be unable to send or receive funds until the owner has a verified status.

Handling incomplete status

An incomplete status occurs when a beneficial owner’s identity scores are too low during the initial verification attempt. Dwolla will trigger a customer_beneficial_owner_reverification_needed event which notifies your application to prompt the Customer to submit another identity verification attempt for the beneficial owner. The second attempt will give our identity vendor more accurate information in an attempt to receive a sufficient score to approve the beneficial owner. The Customer will only have one opportunity to correct any mistakes.
You need to gather new information if the beneficial owner is placed into the incomplete status; simply passing the same information will result in the same insufficient scores. All fields that were required in the initial beneficial owner creation attempt will be required in the incomplete attempt.

Request and Response - update beneficial owner

Check the beneficial owner’s status again. The beneficial owner will either be in the verified or document state of verification.

Handling document status

If a beneficial owner is not verified after being placed in incomplete status and submitting a second verification attempt, the only other state the beneficial owner can be in is document. If the beneficial owner has a status of document, they will need to upload additional pieces of information in order to verify their identity. Use the create a document endpoint when uploading a colored camera captured image of the identifying document. The document(s) will then be reviewed by Dwolla; this review may take anywhere from a few seconds up to 1-2 business days if manual verification is required to approve or reject. You can provide the following best practices to the Customer in order to reduce the chances of a document being rejected:
  • All 4 Edges of the document should be visible
  • A dark/high contrast background should be used
  • At least 90% of the image should be the document
  • Should be at least 300dpi
  • Capture image from directly above the document
  • Make sure that the image is properly aligned, not rotated, tilted or skewed
  • No flash to reduce glare
  • No black and white documents
  • No expired IDs

Determining verification documents needed

US persons
A colored camera captured image of the Beneficial Owner’s identifying document can be specified as documentType: license (state issued driver’s license), or idCard (U.S. government-issued photo id card). Examples include:
  • Non-expired State Issued Driver’s License/Identification Card
  • Non-expired US Passport
  • Federal Employment Authorization Card
  • US Visa
Non-US persons
A colored camera captured image of the Beneficial Owner’s identifying document can be specified as documentType: passport. Examples include:
  • Non-expired Foreign Passport Note: Foreign Passports are only accepted when the individual does not have an ITIN or SSN and the user must alternatively enter the Passport number.

Uploading a document

To upload a color photo of the document, you’ll initiate a multipart form-data POST request from your backend server to the beneficial owners documents endpoint. The file must be either a .jpg, .jpeg, or .png. Files must be no larger than 10MB in size. You’ll also get a beneficial_owner_verification_document_uploaded event to let you know the document was successfully uploaded.
Request and Response

Update Beneficial Owner Information

Information can only be edited or updated when the Beneficial Owner has a status of incomplete. If an individual beneficial owner with a status of verified needs to update their information, that beneficial owner will first need to be removed and re-added.

Request and Response

After removal of a Beneficial Owner, they can be re-added and go through the verification process again. You can also remove a beneficial owner if they no longer own 25% or more of the business. The successful creation and verification of a beneficial owner doesn’t necessarily mean the business verified Customer is verified and ready to send or receive funds. The final step in creating a business verified Customer is to certify that all information provided is correct. Read on to view the procedures on how to certify your owners. To learn how to certify beneficial owners to your Customer, read on to the next step.

Step 4 - Certify Beneficial Ownership

In order for your business verified Customer to be eligible to send funds, the individual creating the business verified Customer account must certify beneficial owner(s). By certifying that all beneficial owner information is correct, the requirements imposed by the United States Federal customer due diligence rule and Dwolla will be successfully fulfilled. Certification of beneficial owners should be included as part of the Customer account registration and immediately following the creation of the business Verified Customer and the addition of all owners (unless exempt).

How do I know what business structure is required to certify Beneficial Ownership?

Determining Certification needed

When a business verified Customer needs to be certified, Dwolla will return a link in the API response after retrieving a Customer. If no certification link is returned, the Customer is either already certified, or is exempt from certification.
Example response

Certification Statuses

Certify ownership

To change the certification status of your business verified Customer account, you will want to POST to the beneficial ownership endpoint. By updating the certification status to certified, the Account Admin creating the business verified Customer is indicating that all information is correct. After the Account Admin certifies that the information provided is accurate and the information the Account Admin submitted has been verified through the identity verified process, your business verified Customer is now ready to transact within the Dwolla network.

Certification Text Example

Example for certification is as follows:

Handling recertify status

If you are adding, removing, or updating information of beneficial owners tied to a business verified Customer account, the certification status will change to recertify. Instances that you will see your certified business verified Customer change to recertify are as follows:
  • Adding a beneficial owner
  • Removing a beneficial owner
  • Updating a beneficial owner in incomplete status
When a Customer has a recertify beneficial ownership status, they will have up to thirty days to update and verify their beneficial owners’ information and update their status to certified. If the certification status isn’t updated within this timeframe, the business verified Customer will have its certification_status changed to uncertified, leaving the Customer unable to transact.

Frequently Asked Questions

Customer Eligibility

You can determine the eligibility of the customer to start transacting in the Dwolla platform by the presence of the send and receive links in the customer resource.

send - Denotes that the customer is eligible to start sending funds if they have a verified funding-source attached.

receive - Denotes that the customer is eligible to receive funds into their Dwolla balance or an attached bank funding-source. Note: Until the following actions have been completed, any funds received by the Customer will remain in their Dwolla Balance unable to be withdrawn or sent to another Customer or Account:


Tip: You can use the MCP server to programmatically check these links via the API.

  • Send funds - No
  • Receive funds - Yes - Note that funds will only process to their balance and the transfer will stay pending until the Customer has been verified.
  • Add and verify a bank funding source - Yes
  • Add and verify a Beneficial Owner - Yes
  • Send funds - No
  • Receive funds - Yes - Note that funds will only process to their balance and the transfer will stay pending until the Customer has been verified.
  • Add and verify a bank funding source - Yes
  • Add and verify a Beneficial Owner - Yes
  • Send funds - No
  • Receive funds - No
  • Add and verify a bank funding source - No
  • Add and verify a Beneficial Owner - No

Your Customer has likely not completed the bank verification process. You can check to see the status of the funding sourcevia the APIor by going into the Dwolla dashboard.

No. Downgrade functionality is not supported for Dwolla Verified Customers.

Yes, although this is not necessary, nor recommended. Dwolla manually reviews all documents, so sending more documents than necessary may slow down the verification process for your Customers.

No. At this time, Dwolla will create Business Verified Customers when they have a proper business EIN or SSN (for Sole Proprietorships only).

Beneficial Owner Eligibility

Your Customer will need to certify beneficial ownership information before your Customer will be eligible to send funds.

  • Send funds - No
  • Receive funds - Yes - Note that funds will only process to their balance and the transfer will stay pending until all of the Beneficial Owners have been verified and certified.
  • Add and verify a bank funding source - Yes
  • If your Beneficial Owner is an individual from the United States with a US-issued SSN, your Beneficial Owner will sign up using ssn.
  • If your Beneficial Owner is a non-US individual, they will use the passport object.